EPA also is contemplating a complete overhaul of the 2004 Wood MACT (Plywood and Composite Wood Panels) rules, brought on by a 2007 court decision that tossed out parts of EPA's 2004 rules and obligated EPA to evaluate any post-MACT health risks and control technology changes eight years later. EPA has now been sued for missing this deadline. It is estimated that this rule could cost as much as $1 billion to implement, if EPA does not use its statutory discretion, and are expected to also include:
- A reassessment of further emission controls for dryers and presses; a residual risk review where EPA must determine if unacceptable public health risks remain after the 2004 MACT's implementation; and a consideration of work practices in lieu of numeric standards where emissions are hard to measure or capture. It is estimated that this rulemaking could cost as much as $1 billion to implement.
EPA also is on a regulatory treadmill to review and potential revise its six National Ambient Air Quality Standards (NAAQS) that cover particulate matter and ozone over the next several years. States, Congress, and even EPA are aware that science does not change so quickly and that the constant ratcheting creates significant business uncertainly in a globally competitive marketplace. Conducting better scientific research on health effects at current lower levels and improving the standard setting framework are needed.
EPA is looking to AWC for leadership in developing a unified industry strategy with allied groups for these environmental issues. That unity will be essential to our success and to help prevent environmental opponents from exploiting differences within the industry to weaken our advocacy and see the most stringent possible regulations imposed.
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